I must review the performance of participant' accounts

Nowhere in the 404(c) Regulations is there any statement that a Plan Fiduciary must regularly review participant's accounts with the intent of identifying those participants who are making poor or even disastrous investment decisions.

The plan fiduciary has no obligation to advise a participant regarding activity in their account under a 404c plan. It is, however, very important for plan fiduciaries to remember that under the prudent expert and co-fiduciary rules (ERISA Sections 404(a)(1) and 405(a)(2)) they have an obligation to regularly oversee and assess the appropriateness of the investment options offered by the plan and the performance of co-fiduciaries and investment managers. The Regulation's emphasis is on the suitability of the investment alternatives, not the suitability of the investment decisions made under independent control of the participant or beneficiary.